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Section 6662 imposes a penalty equal to 20 percent of
any portion of an underpayment of tax that is attributable
to negligence or disregard of rules or regulations. See
sec. 6662(a) and (b). The term "negligence" is defined as
"any failure to make a reasonable attempt to comply with
the provisions of [the Internal Revenue Code]". Sec.
6662(c). This includes any failure to exercise due care or
to do what a reasonable and ordinarily prudent person would
do under the circumstances. See Rybak v. Commissioner, 91
T.C. 524, 565 (1988); Neely v. Commissioner, 85 T.C. 934,
947 (1985). The term "disregard" includes any careless,
reckless, or intentional disregard. Sec. 6662(c).
Petitioners bear the burden of proving that respondent's
determination of negligence is erroneous. See Rule 142(a);
Luman v. Commissioner, 79 T.C. 846, 860-861 (1982).
Under certain circumstances, a taxpayer may avoid the
accuracy-related penalty for negligence by showing that he
or she acted in reasonable and good faith reliance on the
advice of a competent, independent tax professional. See
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